Babudar Complaint 3 64ac576218625

United States District Court
WESTERN DISTRICT OF MISSOURI

WESTERN DIVISION
UNITED STATES OF AMERICA Count One:

Bank Theft
v. 18 U.S.C. § 2113(c)
NMT 10 Years’ Imprisonment, NMT $250,000 Fine
XAVIAR MICHAEL BABUDAR, NMT 3 Years’ Supervised Release, Class C Felony
a/k/a “@ChiefsAholic”
[DOB: 07/03/1994] Count Two:
Interstate Transportation of Stolen Property
18 U.S.C. § 2314
NMT 10 Years’ Imprisonment, NMT $250,000 Fine
NMT 3 Years’ Supervised Release, Class C Felony
$100 Mandatory Special Assessment (Each Count)
CRIMINAL COMPLAINT
Case Number: 23-MJ-00061-JAM (LMC)
1. I, the undersigned complainant, being duly sworn, state the following is true and correct to the best
of my knowledge and belief:
COUNT ONE
2. Between or about March 2, 2022, and April 12, 2022, in the Western District of Missouri and
elsewhere, the defendant, XAVIAR MICHAEL BABUDAR, did receive, possess, conceal, store, barter, sell,
and dispose of approximately $68,540 in U.S. Currency, which had been taken and carried away, with intent to
steal and purloin, from the care, custody, control, management, and possession of the Great Western Bank in
Clive, Iowa, the deposits of which were insured by the Federal Deposit Insurance Corporation at the time of such
taking and carrying away, knowing said money had been stolen, all in violation of Title 18, United States Code,
Section 2113(c).
COUNT TWO
3. Between or about March 2, 2022, and April 12, 2022, in the Western District of Missouri and
elsewhere, the defendant, XAVIAR MICHAEL BABUDAR, did unlawfully transport, transmit, and transfer in
interstate and foreign commerce from Clive, Iowa, to Kansas City, Missouri, stolen goods, wares, and
Case 4:23-mj-00061-JAM Document 1 Filed 05/24/23 Page 1 of 2

Sworn to by telephone
——————————
May 24, 2023 4:17 PM, May 24, 2023
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AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT
I, Cameron Smith, Special Agent with the Federal Bureau of Investigation (“FBI”), being
duly sworn, state the following is true and correct to the best of my knowledge and belief:
1. This affidavit is in support of a criminal complaint charging XAVIAR MICHAEL
BABUDAR (“BABUDAR”), also known as Twitter user “@ChiefsAholic” with bank theft (in
violation of 18 U.S.C. § 2113(c)) and interstate transportation of stolen property (in violation of
18 U.S.C. § 2314).
2. The facts and information contained in this affidavit are based in part on my
consultation with fellow FBI special agents, forensic accountants, and analysts, local law
enforcement officers, responses obtained via search warrants and subpoenas, and an analysis of
various financial records. Because this affidavit is being submitted for the limited purpose of
supporting the criminal complaint, I have not included each and every fact known to me concerning
this investigation, but rather have set forth only the facts that I believe are necessary to establish
the necessary foundation for the requested complaint.
PROBABLE CAUSE
3. On December 16, 2022, BABUDAR was arrested and charged by the Tulsa County
(Oklahoma) District Attorney following a bank robbery in Bixby, Oklahoma. As noted in a story
posted to ESPN.com, BABUDAR – who in the past enjoyed a robust social media presence as a
Kansas City Chiefs superfan Twitter user @ChiefsAholic – was released on bond in February 2023
four days before Super Bowl LVII, in which the Kansas City Chiefs defeated the Philadelphia
Eagles 38-35.1 In late March 2023, BABUDAR removed his ankle monitor and has not yet been
1
Merrill, Elizabeth and Purdum, David. “The mystery of a Kansas City Chiefs superfan charged
with robbery.” ESPN.com, Feb. 17, 2023.
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recovered by authorities.
4. Since BABUDAR’s December 2022 arrest, your Affiant and other investigators
with the FBI have undertaken various investigative techniques and have reviewed bank records,
casino transaction records, and sensitive financial reporting to determine the breadth and scope of
additional potential criminal activities undertaken by BABUDAR. For example, your Affiant has
reviewed various sensitive financial reports which indicate that between April and December 2022,
BABUDAR purchased in excess of $1,000,000 in chips from various casinos in Missouri, Kansas,
and Illinois, and over that same time period redeemed a similar amount from said casinos.2 Due to
BABUDAR’s involvement and arrest for the bank robbery in Bixby, Oklahoma, your Affiant and
others have reviewed unsolved bank robberies throughout the Midwest over that time to determine
a possible provenance of this large volume of money that BABUDAR appears to have moved
through these casinos and his bank accounts over this time.
5. In the course of this investigation, your Affiant has determined that BABUDAR
would travel to various locations throughout the Midwestern United States to perpetrate a string
of robberies at various banks and credit unions before returning home to the Kansas City
Metropolitan area to launder these robbery proceeds through area casinos and deposit these
proceeds in his various bank accounts.
https://www.espn.com/nfl/story/_/id/35652559/chiefsaholic-kansas-city-chiefs-superfan-
arrested-robbery (accessed Apr. 20, 2023.)
2
Your Affiant cautions that the information relayed from these sensitive financial reports is only
a summary of that information which the submitting entities chose to include, and may not
contain the full universe of transactions (purchases and redemptions) known to the submitting
entities. Your Affiant is still receiving the source records which corroborate much of the
information originally contained within these sensitive financial reports, but this analysis is
ongoing and still incomplete at this time and we continue to reconcile these source records with
the sensitive financial reports initially reviewed.
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Figure 1 - Demonstrative map displaying various bank robberies (and attempted bank robberies)
throughout 2022 which your Affiant believes were perpetrated by BABUDAR before he returned
back to Kansas City, Missouri with the proceeds from these robberies.
BABUDAR’s December 2022 Arrest and Charges For Bank Robbery
6. On December 16, 2022, the Bixby (Oklahoma) Police Department (“BPD”)
responded to the Tulsa Teachers Federal Credit Union (“TTCU”), located at 13475 South
Memorial Lane, Bixby, Oklahoma, in response to a bank robbery. According to BPD reports, bank
employees reported that the bank robbery suspect (later identified as BABUDAR), had entered the
bank armed with a black handgun, jumped the teller counter, and ordered a bank employee to the
back vault. Once at the vault, BABUDAR demanded the bank employees to open the vault and to
put the money from the vault into a plastic bag. During the bank robbery, BABUDAR told bank
employees if they did not comply, that he would shoot them. After the money from the vault was
placed in the bag, BABUDAR fled the bank.
7. A review of security footage from TTCU during the bank robbery identified
BABUDAR wearing a grey/green hooded sweatshirt, black and yellow gloves, a black paintball
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mask, and reflective ski goggles. Security footage also identified BABUDAR to be armed with
what appeared to be a black and silver handgun.
8. While responding to the TTCU, BPD established a perimeter of the area. BPD
officers identified BABUDAR fleeing the area on a bicycle, while carrying a large, overstuffed
bag. BPD attempted to make contact with BABUDAR, but he attempted to flee the area.
BABUDAR was ultimately taken into custody by BPD. Upon his arrest, BABUDAR was found
to be in possession of a white plastic bag containing $150,250 in U.S. Currency, a black handgun
(later determined to be a BB-gun), a black ski mask, reflective ski goggles, a pair of black and
yellow gloves, and a grey/green hooded sweatshirt. BABUDAR was taken into custody and
transported to the Tulsa County Jail for Armed Robbery.
9. The following are surveillance photographs of BABUDAR during the robbery at
TTCU:

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10. The following photograph was obtained by BPD of the items recovered from
BABUDAR following his arrest:
11. Following the arrest of BABUDAR, BPD conducted a money count of the U.S.
Currency seized from BABUDAR. BPD identified the white bag seized from BABUDAR incident
to arrest to contain $139,500 in one hundred ($100) dollar bills and $10,750 in fifty ($50) dollar
bills, for a total of $150,250 in U.S. Currency.
12. On December 21, 2022, BPD located a 2019 Mazda 3, bearing Kansas License
Plate (KLP) KCC4EVR, parked at 10642 South Memorial Drive, Tulsa, Oklahoma. A record
check of KLP KCC4EVR revealed it to be registered to BABUDAR. The vehicle was
subsequently seized by BPD.

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13. On December 22, 2022, BPD obtained a search warrant in the District Court of
Tulsa County for BABUDAR’s 2019 Mazda 3. A search of the vehicle revealed the following
items:
x Barstool Sportsbook Betslip for $20,000, dated November 19, 2022;

x FanDuel Betslip for $4,000, dated December 1, 2022;
x Community America Credit Union (“CACU”) letter addressed to BABUDAR,
pertaining to a $20,000.00 deposit, dated May 2, 2022;
x CACU letter addressed to BABUDAR, pertaining to a $50,000.00 deposit, dated May
2, 2022; and
x CACU letter addressed to BABUDAR, confirming a change in contact information for
BABUDAR, which listed (816) 328-1926 as his phone number. The letter to
BABUDAR was dated February 3, 2022.
14. Your Affiant was also provided photographs of the gloves and goggles recovered
from BABUDAR’s vehicle during the search warrant execution. As we note throughout, those
items bear similarities to those same items worn by the person captured on surveillance during the
previously unsolved bank robberies described in the remainder of this affidavit:

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BABUDAR Purchased and Redeemed Over $1 Million in Chips at

Various Casinos Throughout 2022
15. Your Affiant and other FBI investigators have conducted a partial review of
sensitive financial reporting which revealed that throughout 2022 BABUDAR conducted a large
number of casino chip purchases and redemptions from casinos in Missouri, Kansas, and Illinois.
16. Your Affiant has reviewed sensitive financial reporting which revealed that
between April 2022 and December 2022, BABUDAR purchased approximately $1,122,000 in
casino chips from Argosy Casino (Riverside, Missouri, and Alton, Illinois), Bally’s Casino
(Kansas City, Missouri), Harrah’s Casino (North Kansas City, Missouri), Ameristar Casino
(Kansas City, Missouri), Ameristar Casino (St. Charles, Missouri), Hollywood Casino (St. Louis,
Missouri), and Hollywood Casino (Kansas City, Kansas).

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17. This sensitive financial reporting further revealed that between April 2022 and
December 2022, BABUDAR redeemed approximately $1,069,950 in U.S. Currency from casino
chips from Argosy Casino (Riverside, Missouri, and Alton, Illinois), Bally’s Casino (Kansas City,
Missouri), Harrah’s Casino (North Kansas City, Missouri), Ameristar Casino (St. Charles,
Missouri), and Hollywood Casino (St. Louis, Missouri).
FBI Investigators Reviewed Previously Unsolved Bank Robberies throughout the

Midwest in 2022
18. Given BABUDAR’s December 2022 arrest and criminal charges relating to the
Bixby, Oklahoma bank robbery, and the large volume of cash transactions at area casinos and
BABUDAR’s bank accounts in the Western District of Missouri, your Affiant and other FBI
investigators conducted a review of unsolved bank robberies in the Midwest region to account for
BABUDAR’s inexplicable access to large amounts of U.S. Currency throughout 2022.
19. In addition to reviewing these unsolved robberies, your Affiant has attempted to
account for a legitimate source of the large amounts of U.S. Currency that BABUDAR has moved
through area casinos and his bank accounts. Your Affiant has consulted with the Kansas
Department of Labor, and was advised that BABUDAR has not had any reported wages in the
state of Kansas since 2018, and has had no reported wages from any other state since October
2021. Your Affiant has also consulted with FBI forensic accountants that have been reviewing
financial records for BABUDAR, and, other than occasional eBay sales activity, we have not yet
detected a consistent source of wages, revenue, or income from any legitimate employment for
BABUDAR over this time.
20. Your Affiant has also reviewed subscriber records produced by T-Mobile for
BABUDAR’s known cellular device, which was registered to T-Mobile and assigned the cellular

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telephone number (816) 328-1926 (which was previously identified in Paragraph 13). The
“Subscriber Details” information associated with this telephone do not include any name or
address with this account, and it lists the status as “Deactivated” with a subscriber effective date
of August 2, 2021. The sparse and nonexistent subscriber information may be attributed to the
“Account Details” section, which indicates that the “Brand” of account was “TRACFONE,” which
your Affiant knows to be a pay-as-you-go form of mobile wireless service. This section also
indicates the service was terminated on April 1, 2023.
21. While T-Mobile’s records lack any subscriber name associated with this account,
there are corroborating details connecting this telephone number to BABUDAR. As noted in
preceding paragraphs, this telephone number was listed on a change in contact information
correspondence from CACU to BABUDAR. In addition, your Affiant has reviewed a response
from Google relating to the subscriber information for the xaviarbabudar@gmail.com Google
account, which lists (816) 328-1926 as the account recovery SMS and telephone number for this
account. This same telephone number – (816) 328-1926 – is listed as BABUDAR’s in records
maintained by St. Louis Gaming Ventures (d/b/a Hollywood Casino) and Harrah’s North Kansas
City.
22. In addition to placing BABUDAR’s known cellular device in the same cities and
locations for these previously unsolved bank robberies and attempted bank robberies, these records
also show that BABUDAR attended various away games where the Kansas City Chiefs faced off
against the Arizona Cardinals (Phoenix, Arizona on September 11, 2022), Indianapolis Colts
(Indianapolis, Indiana on September 25, 2022), Tampa Bay Buccaneers (Tampa, Florida on
October 2, 2022), Los Angeles Chargers (Los Angeles, California on November 20, 2022), and
the Denver Broncos (Denver, Colorado on December 11, 2022). BABUDAR was a frequent

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presence at Kansas City Chiefs games whether home or away, and this pattern of travel for this
known cellular device is consistent with BABUDAR’s attendance at these games.
23. Your Affiant has also reviewed bank records from BABUDAR’s aforementioned
CACU bank statements which place BABUDAR in some of these same Kansas City Chiefs away
games. For the month of September 2022, BABUDAR’s CACU bank account shows charges
occurring in Phoenix, Arizona and Glendale, Arizona on September 12, 2022 (corresponding with
his suspected attendance at the Chiefs-Cardinals game on September 11, 2022) and at Lucas Oil
Stadium in Indianapolis, Indiana with a posting date of September 26, 2022 (corresponding with
his suspected attendance at the Chiefs-Colts game on September 25, 2022).
24. BABUDAR’s use of this (816) 328-1926 telephone number that is associated with
BABUDAR’s known cellular device was corroborated by a woman who had met BABUDAR in
the fall of 2022 at a Kansas City Chiefs game. This woman was interviewed by FBI special agents
in late April 2023, and advised these agents that BABUDAR’s telephone number was (816) 328-
1926. This woman said that she blocked his telephone number after finding out on the news that
he was responsible for bank robberies.
25. Your Affiant has also reviewed historical cell site location data for BABUDAR’s
known cellular device during the date of the TTCU robbery in Bixby, Oklahoma. On December
16, 2022, BABUDAR’s known cellular device utilized a cell tower at or near 7835 East 106th
Street, Tulsa, Oklahoma 74133 at 9:01 a.m. CST. That location is approximately 3.2 miles north
of the TTCU bank robbery, which occurred at approximately 9:47 a.m. CST. Most significantly,
the cell tower at or near 7835 East 106th Street, Tulsa, Oklahoma is less than half a mile from
where BABUDAR’s vehicle was seized by BPD on December 16, 2022.
26. Your Affiant has not observed any further cell site data from BABUDAR’s known
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cellular device since his December 16, 2022 arrest.
March 2, 2022 Robbery of Great Western Bank (Clive, IA - $70,000)
27. In the course of this investigation, your Affiant and other FBI special agents learned
of a previously unsolved March 2, 2022, bank robbery of the Great Western Bank (“GWB”) branch
located at 13150 Hickman Road, Clive, Iowa. Your Affiant reviewed a police report prepared by
the Clive (Iowa) Police Department (“CPD”) regarding this bank robbery.
28. According to the CPD report, GWB bank employees identified a suspect entering
the bank while wearing a ski mask. The suspect handed the bank teller a note demanding money
and indicating he had a firearm. After providing the suspect with money from the bank, the suspect
left the bank on foot and fled the area. Following the bank robbery, GWB notified CPD and FBI
Omaha that the bank had suffered a loss of $70,000.
29. The following surveillance photographs were provided by GWB to CPD and FBI
Omaha following the bank robbery:
30. Your Affiant has reviewed a photograph of the gloves recovered from
BABUDAR’s vehicle in December 2022, and observed a pair that looks very similar to the ones
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worn by the robber as shown in the screenshot from the GWB robbery:
known cellular device on the dates preceding and during the GWB robbery. These records show
that BABUDAR was in Independence, Missouri on March 1, 2022. On March 2, 2022 – the day
GWB was robbed of $70,000 – BABURAR’s known cellular device utilized a cell tower at or near
1755 59th Place, West Des Moines, Iowa at 1:28 a.m. CST. The location of this cell tower is
approximately 2 miles south-southwest of the GWB robbery location. Later that day, at
approximately 12:47 p.m. CST, BABUDAR’s known cellular device utilized another cell tower
at or near 3580 109th Street NW, Des Moines, Iowa. That location is approximately 3.1 miles
northeast of the GWB robbery location, which occurred at approximately 12:34 p.m. CST.
32. Over the next six weeks, BABUDAR deposited the same approximate amount of
criminal proceeds that were stolen from the GWB robbery into his CACU money market savings
account ending in x1480. This amount was deposited in two separate transactions, the first at the
CACU 64th Street Branch located at 6390 N. Cosby Avenue, Kansas City, Missouri, and the
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second at the CACU Branch at 825 NE Rice Road, Lee’s Summit, Missouri, both of which are
within the Western District of Missouri.
33. On March 17, 2022, fifteen days after the GWB robbery, BABUDAR deposited
$30,000 in his CACU money market account while at the CACU 64th Street Branch located at
6390 N. Cosby Avenue, Kansas City, Missouri, which is within the Western District of Missouri.
34. After depositing a portion of these proceeds in his CACU money market account,
BABUDAR engaged in multiple casino chip purchases and redemptions at the Argosy Casino in
Riverside, Missouri, which is within the Western District of Missouri. Your Affiant has reviewed
casino records produced by Argosy Casino which indicate that, between March 20, 2022, and April
5, 2022, BABUDAR cashed in approximately $97,800 towards casino chips, and cashed out
$106,675 in casino chip redemptions over that same time.
35. On April 12, 2022, approximately forty days after the GWB robbery, BABUDAR
deposited the remaining balance from this bank robbery – $40,000 – into his CACU money market
account while at the CACU Branch located at 825 NE Rice Road, Lee’s Summit, Missouri, which
is within the Western District of Missouri.
36. On March 2, 2022, the same date of the GWB robbery, CPD officers consulted with
other local law enforcement officers, who advised that a K-9 unit had tracked the bank robbery
suspect to the east through the nearby woods and had located one (1) black glove. A CPD officer
located the glove in the nearby woods, and sent a photograph of the glove to a CPD detective. This
CPD detective showed this photograph to bank witnesses, who confirmed this was the glove that
the bank robbery suspect was wearing. This black glove was recovered and was submitted for
DNA analysis. In addition, CPD officers located approximately $1,460 in U.S. Currency in $20
denominations. Based on the recovery of these funds, investigators believe BABUDAR ultimately
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stole $68,540 during the GWB robbery on March 2, 2022.
37. Upon information and belief, your Affiant has learned that, at the time of the March
2022 bank robbery, GWB was organized under the laws of the United States, and was an institution
the deposits of which were insured by the Federal Deposit Insurance Corporation. In May 2022,
GWB merged with First Interstate Bank, which your Affiant understands to be an institution the
deposits of which are insured by the Federal Deposit Insurance Corporation.
April 28, 2022 Robbery of First National Bank of Omaha (Omaha, NE - $170,680)
38. Your Affiant has reviewed a police report prepared by the Omaha (Nebraska)
Police Department (“OPD”) regarding a previously unsolved April 28, 2022, bank robbery of a
First National Bank of Omaha (“FNB”) branch in Omaha, Nebraska.
39. According to this report, on April 28, 2022, OPD responded to the FNB branch at
16770 West Maple Road, Omaha, Nebraska, for a bank robbery. Upon responding, FNB
employees identified a suspect entering the bank with a firearm and ordering bank employees to
open the vault. After bank employees provided the suspect money from the vault and cash drawers,
the suspect left on foot and fled the area. During the course of the investigation, OPD determined
the suspect was provided with a dye pack that exploded. Per initial FBI reporting, FNB reported
the loss to the bank as $170,860. Upon further review, the loss was determined to be $170,680 as
reported by OPD; however, OPD located $163,560. The recovered money was located by OPD in
a wooded area, covered in red dye.
40. The following surveillance photographs were provided by FNB to OPD and FBI
Omaha:
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BABUDAR’s vehicle, and observed a pair that looks very similar to the ones worn by the robber
as shown in the screenshot from the FNB robbery:
between April 28, 2022, and July 9, 2022, BABUDAR conducted casino chip purchases
transactions totaling approximately $568,000 at casinos in Arizona, Missouri, and Illinois. Your
Affiant has reviewed sensitive financial reporting which revealed that between those same dates,
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BABUDAR conducted redemptions of casino chips totaling approximately $662,900 at casinos in
Missouri, Oklahoma, Arizona, and Illinois.
known cellular device during the date of the FNB robbery. On April 28, 2022, BABUDAR’s
known cellular device utilized a cell tower at or near 609 North 108th Circle, Omaha, Nebraska
68154 at 10:24 a.m. CST. That location is approximately 7.4 miles west of the FNB robbery
location, which occurred at 3:11 p.m. CST. On April 29, 2022, the day following the FNB robbery,
BABUDAR’s known cellular device utilized various cell towers in St. Joseph, Platte City, and
Kansas City, Missouri, which is consistent with BABUDAR driving from Omaha back to the
Kansas City area.
July 13, 2022 Robbery of First Class Credit Union (Des Moines, IA - $303,845)
44. Your Affiant has reviewed a police report prepared by the West Des Moines (Iowa)
Police Department (“WDMPD”) regarding a previously unsolved July 13, 2022, bank robbery of
a First Class Credit Union (“FCCU”) branch in West Des Moines, Iowa.
45. According to this report, on July 13, 2022, WDMPD responded to the FCCU
branch located at 2051 Westown Parkway, West Des Moines, Iowa, for a bank robbery. Upon
responding to FCCU, bank employees informed WDMPD an unknown suspect entered the bank
with a black and silver pistol and jumped over the teller counter. The suspect demanded bank
employees to open the bank vault. FCCU bank employees complied with the suspect’s demands,
and then provided the suspect with currency from the cash drawers and bank vault. The suspect
then left the bank on foot and fled the area.
46. Following the bank robbery, FCCU notified WDMPD and FBI Omaha that the bank
had suffered a loss of $303,845.
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47. The following surveillance photographs of the bank robbery suspect were obtained
from FCCU by WDMPD:
as shown in the screenshot from the FCCU robbery:
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49. Upon information and belief, your Affiant has learned that FCCU is a State-
chartered credit union, the accounts of which are insured by the National Credit Union
Administration Board.
known cellular device during the date of the FCCU robbery. On July 13, 2022, BABUDAR’s
known cellular device utilized a cell tower at or near 1264 225th Avenue, Osceola, Iowa 64068 at
12:59 p.m. CST. That location is 35.7 miles south of the FCCU robbery location, which occurred
at 11:52 a.m. CST. Later that day, BABUDAR’s known cellular device utilized various cell towers
in Liberty, North Kansas City, Independence, and Kansas City, Missouri, which is consistent with
BABUDAR driving from Iowa back to the Kansas City area.
51. On July 14, 2022, the day following the FCCU robbery, BABUDAR deposited
$23,000 in cash in his CACU money market account at the CACU Branch at 825 NE Rice Road,
Lee’s Summit, Missouri, which is within the Western District of Missouri. On July 15, 16, and 17,
2022, BABUDAR purchased $32,200, $79,500, and $20,000 respectively in casino chips from the
Ameristar at 1 Ameristar Boulevard, St. Charles, Missouri 63301 for a total of $131,700. On July
18, 2022, BABUDAR deposited another $40,000 into his CACU money market account using the
“shared branch” location of Neighbors Credit Union at 355 Howdershell Road, Florissant,
Missouri 63031.
November 17, 2022 Robbery of Tennessee Federal Credit Union (Nashville, TN - $125,900)
52. Your Affiant has reviewed a police report prepared by the Metropolitan Nashville
Police Department (“MNPD”) regarding a robbery of a Tennessee Federal Credit Union (“TFCU”)
branch in Nashville, Tennessee, on November 17, 2022.
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53. According to this report, on November 17, 2022, MNPD responded to the TFCU
branch located at 7527 Highway 70 South, Nashville, Tennessee, for a bank robbery. Upon
responding to TFCU, bank employees informed MNPD and FBI Memphis the suspect entered the
bank with a black and silver firearm and climbed over the bank teller counter. The subject pressed
the firearm to the victim teller’s body and demanded bank employees take him to the vault. TFCU
employees complied with the suspect’s demands and provided the suspect with currency from the
cash drawers and bank vault. The suspect told bank employees if he was given a dye pack he
would “come back and put a hole in your head.” The suspect then left the bank on foot and fled
the area. The credit union suffered a loss of $125,900. The following surveillance photographs of
the bank robbery suspect were obtained from TFCU by MNPD and FBI Memphis:
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BABUDAR’s vehicle, and observed a pair that looks very similar to the ones in the screenshots
from the TFCU robbery:
between November 18, 2022, and December 7, 2022, BABUDAR conducted 4 casino chip
purchase transactions totaling $130,000 at casinos in Missouri and Kansas. According to this
reporting, these casino chip purchases were conducted at Ameristar Casino (St. Charles, Missouri),
Hollywood Casino (Kansas City, Kansas), Harrah’s Casino (North Kansas City, Missouri), and
Argosy Casino (Riverside, Missouri).
between November 18, 2022, and December 7, 2022, BABUDAR conducted 3 redemptions of
casino chips totaling $77,400 at casinos in Missouri and Illinois. According to this reporting, these
casino chip redemptions were conducted at Harrah’s Casino (North Kansas City, Missouri) and
Argosy Casino (Alton, Illinois).
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known cellular device during the date of the TFCU robbery. On November 17, 2022,
BABUDAR’s known cellular device utilized a cell tower at or near 201 Forrest Valley Drive,
Nashville, Tennessee 37221 at 9:44 a.m. CST. That location is approximately 4.4 miles north of
the TFCU robbery location, which occurred at 9:26 a.m. CST.
DNA Analysis Matches Glove Recovered from March 2, 2022 Clive, Iowa Robbery to Hat
Recovered from November 17, 2022 Nashville, Tennessee Robbery
58. On November 17, 2022, a hat matching the description of the hat worn during the
TFCU robbery was collected by the FBI from a wooded area to the south of the robbery location,
and that same day the hat was provided to the Tennessee Bureau of Investigation, Nashville Crime
Laboratory, for DNA analysis.
59. Your Affiant is aware that on May 17, 2023, the University of Nebraska Medical
Center (“UNMC”) Human DNA Identification Laboratory notified the FBI that DNA collected
and tested by the UNMC from the glove recovered at the March 2, 2022 GWB robbery in Clive,
Iowa, matched the DNA collected from the hat recovered following the November 17, 2022 TFCU
bank robbery in Nashville, Tennessee. See Paragraph 36.
November 29, 2022 Attempted Robbery of Wings Financial Credit Union (Savage, MN)
60. Your Affiant has reviewed a police report prepared by the Savage (Minnesota)
Police Department (“SPD”) regarding an attempted robbery on November 29, 2022, of a Wings
Financial Credit Union (“WFCU”) branch in Savage, Minnesota.
61. According to this report, on November 29, 2022, the SPD responded to the WFCU
branch located at 14411 Highway 13 South, Savage, Minnesota. Upon responding, WFCU bank
employees stated a suspect entered the bank with a firearm and demanded that bank employees
21

23-MJ-00061-JAM (LMC)
open the vault. Bank employees opened the vault, but upon seeing it only held small bills, the
suspect left the bank on foot and fled the area. WFCU suffered no loss in the bank robbery attempt.
62. The following surveillance photograph was provided by WFCU to SPD and FBI
Minneapolis:
63. Your Affiant is aware that on December 13, 2022, FBI Minneapolis special agents
obtained a search warrant from T-Mobile USA Inc. to obtain cellular tower dump records for the
time period and location of the WFCU bank robbery attempt (as well as another attempted robbery
which occurred on that same date, which is descibed in the following section).
64. Your Affiant has been advised that on March 2, 2023, FBI Minneapolis
investigators conducted an analysis of the T-Mobile USA Inc. tower dump records obtained
through this court order. The analysis revealed that a cellular device assigned telephone number
(816) 328-1926, which has since been identified as BABUDAR’s known cellular device, was in
the location of the WFCU attempted bank robbery in Savage, Minnesota, and in the location of the
Royal Credit Union (“RCU”) attempted bank robbery in Apple Valley, Minnesota, described
below.
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known cellular device during the date of the attempted robberies of WFCU and RCU. These
records show that BABUDAR’s known cellular device utilized a cell tower at or near 8320 153rd
Place, Savage, Minnesota at 11:40 a.m. CST. The location of this cell tower is approximately 1.6
miles aware from the WFCU, which was robbed approximately twenty minutes later at 12:01 p.m.
CST.
November 29, 2022 Attempted Robbery of Royal Credit Union (Apple Valley, MN)
66. Your Affiant has reviewed a police report prepared by the Apple Valley
(Minnesota) Police Department (“AVPD”) regarding an attempted robbery on November 29, 2022,
of a RCU branch in Apple Valley, Minnesota.
67. According to this report, on November 29, 2022, AVPD responded to a RCU
branch located 14295 Cedar Avenue, Apple Valley, Minnesota, for a bank robbery. Upon
responding, RCU bank employees stated a suspect entered the bank with a firearm and demanded
that bank employees open the vault. Bank employees opened the vault, but upon seeing it only
held small bills, the suspect demanded $100 bills. Bank employees told the suspect they did not
keep $100 bills in the vault. The suspect did not take any of the money from the vault, and left the
bank on foot, fleeing the area. RCU suffered no loss in the bank robbery attempt.
68. The following surveillance photographs were provided by RCU to AVPD and FBI
Minneapolis:
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69. As noted in a preceding paragraph, your Affiant has been advised an analysis
conducted by FBI Minneapolis investigators revealed that the cellular device assigned telephone
number (816) 328-1926 which is associated with BABUDAR was in the location of the RCU
attempted bank robbery in Apple Valley, Minnesota.
70. Your Affiant has also since reviewed historical cell site location data for
BABUDAR’s known cellular device during the date of the attempted robberies of the WFCU and
RCU. These records show that BABUDAR’s known cellular device utilized a cell tower at or near
7300 147th Street W, Apple Valley, Minnesota at 1:26 p.m. CST. The location of this cell tower
is approximately 0.8 miles away from the RCU, which was robbed approximately eleven minutes
later at 1:37 p.m. CST.
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November 30, 2022 Robbery of First Interstate Bank (Clive, IA - $25,000)
71. Your Affiant has reviewed a police report prepared by the CPD regarding the
November 30, 2022 robbery of a First Interstate Bank (“FIB”) branch in Clive, Iowa.
72. According to this report, on November 30, 2022, CPD responded to the FIB branch
located at 13150 Hickman Road, Clive, Iowa, for a bank robbery. Upon responding, FIB bank
employees identified a suspect entering the bank, jumping over the teller counter, and ordering the
bank employees to open the vault at gunpoint. After providing the suspect with money from the
bank vault, the suspect left the bank on foot and fled the area.
73. Following the bank robbery, FIB notified CPD and FBI Omaha that the bank had
suffered a loss of $25,000.
74. The following surveillance photograph of the bank robbery suspect was provided
by FIB to CPD:
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75. Your Affiant has reviewed a photograph of the goggles recovered from
as shown in the screenshot from the FIB robbery:
76. Your Affiant has reviewed casino records which revealed that on December 7,
2022, a week after the FIB robbery, BABUDAR purchased $20,000 of casino chips from Harrah’s
Casino located in North Kansas City, Missouri, which is within the Western District of Missouri.
These records further show that on the following day, December 8, 2022, BABUDAR redeemed
$32,000 from casino chips from this same casino.
77. Your Affiant has also since reviewed historical cell site location data for
BABUDAR’s known cellular device on the date of the FIB robbery. On November 30, 2022,
BABUDAR’s known cellular device utilized a cell tower at or near 4935 78th Street, Urbandale,
Iowa 50322 at 11:16 a.m. CST. That location is approximately 6.7 miles northeast of the FIB
robbery location, which occurred at 10:18 a.m. CST.
78. Upon information and belief, your Affiant has learned that FIB is organized under
the laws of the United States, and is an institution the deposits of which are insured by the Federal
Deposit Insurance Corporation.
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Summary of Robberies, Attempted Robberies, and Financial Transactions
79. In summary, your Affiant has observed records indicating that BABUDAR has
engaged in suspicious transactions subsequent to many of these previously unsolved bank
robberies from the spring of 2022 through December 2022, or have determined that BABUDAR
was in close proximity to two unsuccessful bank robberies in which the assailant is dressed
similarly to those in the other completed bank robberies:
Bank Date Amount Suspicious Historical Post-

Stolen Transactions Cell Site Robbery
(Approximate) Location Return to
WDMO
1 GWB; 3/2/22 $70,000 $70K deposited into West Des 3/17/22
Clive, IA BABUDAR’s Moines,
Community America IA
Credit Union b/w
3/17/22 and 4/12/22;
$68K withdrawn from
acct. b/w 4/5/22 and
4/20/22, and $65K
deposited into acct.
from casinos b/w
4/15/22 and 4/21/22
2 FNB; 4/28/22 $170,680* $568K in chip Omaha, 4/29/22
Omaha, purchases b/w 4/28/22 NE
NE *$163,560 and 7/9/22; $662,900 in
was chip redemptions b/w
immediately 4/28/22 and 7/9/22
recovered
3 FCCU; 7/13/22 $303,845 $290,000 in chip West Des 7/13/22
Des purchases b/w 7/13/22 Moines
Moines, and 10/12/22; $233,400 and
IA in chip redemptions Osceola,
b/w 7/13/22 and IA
10/12/22
4 TFCU; 11/17/22 $125,900 $130k in chip Nashville, 11/19/22
Nashville, purchases b/w 11/18/22 TN
TN and 12/7/22; $77,400 in
chip redemptions b/w
11/18/22 and 12/7/22
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5 WFCU; 11/29/22 N/A None; cell tower hit on Savage, 11/30/22

Savage, phone MN
MN
6 RCU; 11/29/22 N/A None; cell tower hit on Apple 11/30/22
Apple phone Valley,
Valley, MN
MN
7 FIB; 11/30/22 $25,000 $20k in chip purchases Urbandale, 11/30/22
Clive, IA at Harrah’s on 12/7/22 IA
8 TTCU; 12/16/22 $150,250 N/A; money was in Tulsa, OK N/A
Bixby, duffel bag recovered
OK from BABUDAR
Criminal Statutes
80. The crime of bank theft and incidental crimes is found under 18 U.S.C. § 2113(c),
which states:
Whoever receives, possesses, conceals, stores, barters, sells, or disposes of, any
property or money or other thing of value which has been taken or stolen from a
bank, credit union, or savings and loan association in violation of subsection (b),
knowing the same to be property which has been stolen…[shall be fined under this
title or imprisoned not more than ten years, or both].
81. The crime of transportation of stolen money is found under 18 U.S.C. § 2314, which
states:
Whoever transports, transmits, or transfers in interstate or foreign commerce any

goods, wares, merchandise, securities or money, of the value of $5,000 or more,
knowing the same to have been stolen, converted or taken by fraud…[s]hall be
fined under this title or imprisoned not more than ten years, or both.
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Background of the Affiant
82. I have been employed as a Special Agent of the Federal Bureau of Investigation
(FBI) since September of20 18 and am currently assigned to the Complex Financial Crimes Squad
in Kansas City. I received my initial training and instruction to become a Special Agent at the FBI
Academy located in Quantico, Virginia where I received training concerning violations of the
United States criminal statutes. During the normal course of my duties, I conduct investigations
involving a variety of criminal violations, to include violations of federal statutes involving bank
fraud and wire fraud.
Respectfully submitted,
cat(smi~
Special Agent
Federal Bureau of Investigation
Subscribed and sworn to me via telephone on

May 24, 2023 _ 4:17 PM, May 24, 2023
HON. LAJUANA M. COUNTS

UNITED STATES MAGISTRATE JUDGE
29

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United States District Court

WESTERN DISTRICT OF MISSOURI

UNITED STATES OF AMERICA Count One:

$100 Mandatory Special Assessment (Each Count)

Case 4:23-mj-00061-JAM Document 1 Filed 05/24/23 Page 1 of 2

May 24, 2023 4:17 PM, May 24, 2023

Case 4:23-mj-00061-JAM Document 1 Filed 05/24/23 Page 2 of 2

AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT

1. This affidavit is in support of a criminal complaint charging XAVIAR MICHAEL

the necessary foundation for the requested complaint.

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 1 of 29

proceeds in his various bank accounts.

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 2 of 29

6. On December 16, 2022, the Bixby (Oklahoma) Police Department (“BPD”)

placed in the bag, BABUDAR fled the bank.

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 3 of 29

what appeared to be a black and silver handgun.

transported to the Tulsa County Jail for Armed Robbery.

9. The following are surveillance photographs of BABUDAR during the robbery at

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 4 of 29

BABUDAR following his arrest:

bills, for a total of $150,250 in U.S. Currency.

check of KLP KCC4EVR revealed it to be registered to BABUDAR. The vehicle was

subsequently seized by BPD.

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 5 of 29

x Barstool Sportsbook Betslip for $20,000, dated November 19, 2022;

previously unsolved bank robberies described in the remainder of this affidavit:

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 6 of 29

BABUDAR Purchased and Redeemed Over $1 Million in Chips at

Missouri), and Hollywood Casino (Kansas City, Kansas).

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 7 of 29

Missouri), and Hollywood Casino (St. Louis, Missouri).

FBI Investigators Reviewed Previously Unsolved Bank Robberies throughout the

BABUDAR’s inexplicable access to large amounts of U.S. Currency throughout 2022.

BABUDAR over this time.

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 8 of 29

indicates the service was terminated on April 1, 2023.

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 9 of 29

known cellular device is consistent with BABUDAR’s attendance at these games.

his suspected attendance at the Chiefs-Colts game on September 25, 2022).

he was responsible for bank robberies.

where BABUDAR’s vehicle was seized by BPD on December 16, 2022.

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 10 of 29

cellular device since his December 16, 2022 arrest.

March 2, 2022 Robbery of Great Western Bank (Clive, IA - $70,000)

Omaha that the bank had suffered a loss of $70,000.

Omaha following the bank robbery:

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 11 of 29

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 12 of 29

within the Western District of Missouri.

$106,675 in casino chip redemptions over that same time.

is within the Western District of Missouri.

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 13 of 29

stole $68,540 during the GWB robbery on March 2, 2022.

deposits of which are insured by the Federal Deposit Insurance Corporation.

First National Bank of Omaha (“FNB”) branch in Omaha, Nebraska.

a wooded area, covered in red dye.

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 14 of 29

as shown in the screenshot from the FNB robbery:

Case 4:23-mj-00061-JAM Document 1-1 Filed 05/24/23 Page 15 of 29

BABUDAR conducted redemptions of casino chips totaling approximately $662,900 at casinos in

Missouri, Oklahoma, Arizona, and Illinois.

Kansas City area.

then left the bank on foot and fled the area.